ML20093D853

Interrogatories to Intervenor Bob Neiner Farms,Inc.,Et Al. Certificate of Svc Encl

ML20093D853
Person / Time
Site:	Braidwood
Issue date:	10/08/1984
From:	Lauer R COMMONWEALTH EDISON CO., ISHAM, LINCOLN & BEALE
To:	NEINER, B. (BOB NEINER FARMS, INC.)
References
CON-#484-422 OL, NUDOCS 8410110433
Download: ML20093D853 (8)

Text

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3 ,M RELATED CORRESPONDENCE

.g UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION E4 0Ci11 00 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Crr GCC cc , EECQ;;;

In.the Matter Of: )

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COMMONWEALTH EDISON COMPANY )

) Docket Nos. 50-456 (--

(Braidwood Nuclear Power ) 50-457 O L-Station, Units l'and 2) )

INTERROGATORIES TO INTERVENOR BOB NEINER FARMS, INC., ET AL.

Applicant, Commonwealth Edison Company, hereby serves upon Intervenor Bob Neiner Farms, Inc., et al.

written interrogatories pursuant to 10 C.F.R. $2.740b. Each interrogatory should be answered separately and fully in writing, under oath or affirmation, within 14 days after service.

Neiner Farms Contention 1

1. Identify the document (s) which or the per-son (s) whose opinion (s) provide (s) Intervenor's basis for the conclusion that 765 kV transmission lines create each of the following alleged conditions for persons who are within 600 feet of the line for six or more hours per day:

a) audible noise impairing hearing; b) ' increasing tension; 8410110433 841008 PDR ADOCK 05000456 G ppg _

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c) sleep interference; d) interference with the operation of cardiac pacemakers; e) biological effects on humans because of

. exposure to electric fields excluding the use of nearby areas for working, living, or recreation; and f) danger of shock to persons and animals.

2. State with particularity the basis for the tassumption that 765 kV transmission lines will be con-structed within 600 feet of where persons would have oc-casion to be for six or more hours per day. If persons

. exist who would.have occasion to be within 600 feet of such lines for six or more hours per day, identify each such person by name and address.

3. State whether Intervenor agree.= that the fields associated with parallel 345 kV and 765 kV lines would be, at worst, only slightly higher than an average of 2.4 kV/m (maximum 6.9 kV/m) for lines at a height of 1 m.

(See Braidwood Final Environmental Statement (FES) at 45.5.1.2 and Braidwood Environmental Report-Operating Li-cense Stage (ER-OLS) at S3.9.6). If Intervenor disagrees with this conclusion, state with particularity the basis for

.such disagreement.

4.- State whether Ir.tervenor agrees with the NRC Staff's conclusions in the FES at 55.5.1.2 that "[f]or the most part, adverse effects have been demonstrated only for

Y higher fields (e.g., greater than 15 kV/m) or longer ex-posure times than would occur for people residing near or working under transmission lines." If Intervenor disagrees with this conclusion, state with particularity the basis for such disagreement.

Neiner Farms Contention 5

1. Identify the type of contamination with which Intervenor is concerned in Contention 5.

2. Define the level of contamination which In-tervenor contends is unacceptable and the basis for that conclusion.

3. Define the mechanism or conduit by which In-tervenor believes seepage from the cooling lake will occur.

4. State with particularity those aspects, if any, in which Intervenor believes the monitoring programs described in S5.9.3.4 and Table 5.7 of the FES and in SS6.1.2 and 6.1.5 of the ER-OLS are deficient for the pur-pose of detecting unacceptable groundwater contamination as defined by Intervenor in response to interrogatories 1 and 2 l above.

5. In light of the NRC Staff's description of the soils around and beneath the cooling lake and the Staff's conclusion that the effect of seepage from the cooling lake

W "onl local ground levels will be negligible and will be restricted to the immediate perimeter of the cooling pond" (See FES at S4.3.1.5.2), state with particularity the. basis

-for the contention that Applicant must establish an offsite monitoring program.

Neiner Farms Contention 6

1. State whether Intervenor contends that the environmental impact studies should consider the cumulative effects of. discharges resulting from routine operation or resulting from a postulated accident.

2. Identify the types of chemicals contemplated-by Intervenor in Contention 6.

Neiner Farms' Contention'7

1. In light of the NRC Staff's analysis of and conclusions regarding the environmental impacts of postulated accidents described in S5.9.4 of the FES, state with parti-cularity the basis for Intervenor's contention that "the potential that'these facilities would have to be closed, either temporarily or permanently, due to the release of substantial quantities of radioactive materials during an accident. creates an unacceptable environmental impact."

4 Neiner Farms Contention 10

1. State whether Intervenor's contention con-cerns air-borne or groundwater radioactive releases.

2. State whether Intervenor's contention con-cerns radioactive releases as a result of normal plant operation or as a result of a postulated accident.

3. State with particularity the basis for In-tervenor's suggestion that the radiological environmental monitoring programs referenced in 55.9.3.4 of the FES are insufficient to provide adequate protection against possible cumulative radioactive doses.

Neiner Farms Contention 11

1. In light of the NRC Staff's conclusion that "it is highly unlikely that the dikes will fail due to heavy precipitation" (FES at S4.3.1.1.5) and that failure of the dikes will not cause loss of the minimum level assumed for the ultimate heat sink design-basis capability (Safety Evaluation Report, NUREG-1002 at S9.2.5; FES at $4.2.4.2),

state with particularity the basis for-Intervenor's Con-tention 11.

.I Submitted by:

Rebecca X Lauer One Of The Attorneys For Applicant COMMONWEALTH EDISON COMPANY Joseph Gallo, Esq.

- Victor G. Copeland, Esq.

-ISHAM, LINCOLN & BEALE 1120 Connecticut Avenue, N.W.

Suite 840 Washington, DC 20036 (202).833-9730 Rebecca J. Lauer, Esq.

ISHAM, LINCOLN.& BEALE Three First National Plaza Suite 5200 Chicago, Illinois 60602 (312) 558-7500 i

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h UNITED STATES OF AMERICA Sukgf0 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY'AND LICENSIN BMf 477 ,.g In the Matter Of: ) T,b[gfj% 't ' <

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COMMONWEALTH EDISON COMPANY )

) Docket Nos. 50-456 0 L.

(Braidwood Nuclear Power ) 50-457 UD Station, Units 1 and 2) )

CERTIFICATE OF SERVICE I, Rebecca J. Lauer, one of the attorneys for 4 Commonwealth Edison Company, certify that copies of the Interrogatories To Intervenor Bob Neiner Farms, Inc., Et A1. have been served in the above-captioned matter on those persons listed in the attached Service List by United States mail, postage prepaid, this 8th day of October, 1984.

Rebecca 3. Lauer ISHAM, LINCOLN & BEALE Three First National Plaza Suite 5200 Chicago, Illinois 60602

-(312) 558-7500 DATED: October 8, 1984

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SERVICE LIST Marshall E. Miller, Esq. Mr. Scott W..Stucky 1 Chairman- Chief, Docketing and Services Administrative Law Judge United States Nuclear-Regulatory Atomic Safety and Licensing Commission

Board. Office of the Secretary United _ States Nuclear Regulatory Washington, DC 20555 Commission

. Washington, DC 20555 C. Allen Bock, Esq.

P.O. Box 342 Dr. Richard F. Cole Urbana, IL 61801

-Administrative Law Judge Atomic _ Safety and Licensing Board Thomas J. Gordon, Esq.

United States Nuclear Regulatory Waaler, Evans.& Gordon Commission .

2503 South Neil

' Washington, DC 20555 Champaign, IL 61820 Dr . A .' Dixon Callihan Ms. Bridget Little Rorem Administrative Law Judge 117 North Linden Street Union Carbide Corporation Essex, IL 60935 P.O. Box "Y" Oak Ridge, TN 37830 Jane M. Whicher, Esq.

BPI Myron Karman, Esq. 109 North Dearborn Street Office of the Executive Legal Suite 1300

. Director Chicago, IL 60602 United States Nuclear Regulatory Commission Washington, DC 20555 Ms. Lorraine Creek Route 1 Box 182 Atomic Safety and Licensing Manteno, IL 60950 Board Panel United States Nuclear Regulatory Commission Erie Jones, Director Washington, DC 20555 Illinois Emergency Services and Disaster Agency 110 East Adams Atomic Safety and Licensing Springfield, IL 62705 Appeal Board Panel United States Nuclear Regulatory Commission Washington, DC 20555